OECD: Meeting of the Inclusive Framework on BEPS
On 1 July 2020 the OECD Secretary General delivered the opening address for the July 2020 meeting of the Inclusive Framework on base erosion and profit shifting (BEPS). The countries involved in the Inclusive Framework are working towards
See MorePoland: Ministry of Finance further extends TP documentation deadline due to COVID 19
On 24 June 2020, the Polish Ministry of Finance announced the further extension of transfer pricing documentation deadlines due to the coronavirus pandemic. The announcement extends the local transfer pricing documentation preparation deadline as
See MoreDenmark: Supreme Court makes a decision regarding royalties and TP documentation
On 25 June 2020, the Supreme Court made a decision on a case, entitled “Denmark vs. Adecco A/S”, in favor of Danish company, Adecco, and its Swiss parent company in a dispute involving the deductibility of royalties and the sufficiency of
See MoreKazakhstan deposits MLI ratification instrument
On 24 June 2020, OECD has published the updated position of signatories’ countries regarding the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Accordingly, Kazakhstan on 24
See MoreIreland: Tax authority extends the DAC6 reporting timelines by six months
Due to coronavirus outbreak, the European Commission has recently agreed to delay the entry into force of certain European Union (EU) taxation measures. Among these is the delay of Council Directive 2018/822, commonly known as the Directive on
See MoreSweden: Tax Agency extends deadlines for DAC6 reporting amid COVID-19
On 24 June 2020, the Swedish Ministry of Finance published a statement announcing its intension to extend the reporting deadline of EU directive on reporting requirements for certain cross-border transactions (DAC6) due to the outbreak of the
See MoreCzech Republic: Financial Administration announces to expect a delay on DAC6 implementation
Amid COVID-19 pandemic, and in response to requests from European trade associations, the European Commission has published its proposal to amend Directive 2011/16/EU which deals with various strands of administrative co-operation in the field of
See MoreBelgium declares guidelines on EU directive DAC6
On 26 June 2020, the Belgian tax authorities published a circular on the EU directive on mandatory disclosure of cross-border arrangements (DAC6) with effective from 1 July 2020. The published circular provides guidelines on the interpretation
See MoreCyprus: House of Representatives passed the law to implement EU ATAD
On 19 June 2020, the Cyprus Parliament adopted the law to implement the provisions EU Anti-Tax Avoidance Directive (ATAD I) with respect to exit taxation rules, as well as, the provisions of the amending Directive (ATAD II) with respect to
See MoreOECD: Global Forum Launches Website
The Global Forum has launched a website giving an overview of worldwide progress on the implementation of global tax transparency and exchange of information standards. The Global Forum which has 161 member countries is mandated to ensure
See MoreNetherlands updates mutual agreement procedures
On 22 June 2020, the Ministry of Finance issued a decree updating the mutual agreement procedures (MAP). The decree is effective retroactively to 11 June 2020, and replaces a prior (2008) decree. The decree was updated to reflect recent
See MoreAustralia updates instructions for local file 2020
The Australian Taxation Office (ATO) updated the instructions for local file. These instructions apply to the local file for 2020. This relates to reporting periods starting on or after 1 January 2019. According to the instructions, local file
See MoreDominican Republic: DGII announces further extension of the tax filing deadlines obligations
On 21 June 2020, the Directorate General of Internal Revenue (DGII) announced to extend the submission deadlines of tax return of both legal entities and individual until 29 July 2020 for the fiscal year closed 31 December 2019. Similarly, the DGII
See MoreUS: Supreme Court Will Not Review Ninth Circuit Decision in Altera case
On 22 June 2020 the US Supreme Court announced that it would not review the Ninth Circuit panel decision in the Altera case. The Ninth Circuit decision of 7 June 2019 that upheld the validity of US cost sharing regulations therefore still
See MorePoland: Parliament passes a law implementing ATADII & DAC 6
On 18 June 2020, the higher chamber of the parliament passed a bill implementing the rules related to hybrid mismatches with third countries (ATAD II) and completing the transposition of the DAC 6 rules in its domestic legislation. Under the
See MoreSweden: Tax Agency updates guidance on DAC6 reporting
On 18 June 2020, the Swedish Tax Agency issued updated guidance on the implementation of an EU Council Directive (EU) 2018/822, on the mandatory automatic exchange of information in relation to reportable cross-border arrangements (DAC6). The
See MoreMalaysia: IRB posts FAQs on advance pricing agreement due to coronavirus pandemic
On 16 June 2020, the Malaysian Inland Revenue Board posted online FAQs on advance pricing arrangement (APA) procedures for businesses due to the coronavirus pandemic. The questionnaire covers the filing of new APA applications; the treatment of
See MoreAustralia: Guidance on the Impact of the COVID-19 Crisis on Transfer Pricing Arrangements
On 19 June 2020 the Australian Taxation Office (ATO) posted to its website guidance entitled COVID-19 economic impacts on transfer pricing arrangements. This sets out guidance for taxpayers affected by COVID-19 who are preparing transfer pricing
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